Family Office Compliance Policies and Record Keeping

Kirby : Welcome to the Tamarind Learning Podcast, I'm your host Kirby Rosplock. And today we have David Guin Attorney at Withers, who is a compliance expert.  And we're thrilled to talk to him more about how family offices are complying and this New Day and Age, David, welcome to the podcast.

David: Thanks Kirby. Great to be here.

Kirby: David, can you tell us a little more about what regulations are currently affecting family offices, and how they're managing those regulations?

David: Sure. So, the questions we get asked most frequently by clients are questions dealing with their qualification under the family office exemption. So, do I get to skip being registered as an investment advisor? Questions about beneficial ownership reporting? So, when, when do I have to disclose to the public my ownership interest in securities.  Then, we have questions about privacy and, just, overall recordkeeping requirements.

Kirby: And if we go dig, dig deeper a little bit here, can you also just share with people listening in, what are the requirements for the family office exemption?

David: So, there's two overarching requirements. One is that the family office needs to be owned and controlled by the family, and, secondly, the family office can only serve an investment advisory capacity anyway, entities and individuals that qualify as family clients. So, one of the questions we get asked about frequently, for example, is, I want to do some type of no recordkeeping reporting, performance reporting for a non family member. Can I do that? Of course, you can't. Because doing that type of, I like to say math is not a regulated activity. Computer simply crunching numbers for people, that isn't a regulated activity. You can provide that for anyone. So we get a fair amount of questions about what type of service can I provide, and who can I provide it to? We also still get a fair number of questions about who is or is not a family client.

02:18 - 02:33
Guin, David
So, you know, as people's families change, whether or not someone qualifies as a family client, we got an interesting one, not too long ago, our client called, and in their case, they had a former family member.


02:33 - 02:40
Guin, David
So, a former spouse, and they were asking whether the children of the former spouse.

02:40 - 02:41
Kirby Rosplock
Or.

02:41 - 02:42
Guin, David
Family clients?

02:42 - 02:46
Guin, David
And interestingly, it depends on when those children were born.

02:46 - 02:54
Guin, David
So, if they were born, during the time that the former spouse was a spouse of a family member, then they do qualify.

02:55 - 02:57
Guin, David
If they were born after that time, they don't qualify.

02:58 - 03:05
Guin, David
And, I guess, I'm not really sure that's where the SEC intended that, to end up, But that's, if you look at the rules, that's where it ends up.

03:05 - 03:12
Guin, David
So, there's still interpretation questions that are coming up, that that aren't specifically dealt with in the rules.

03:14 - 03:15
Kirby Rosplock
That's really interesting.

03:15 - 03:23
Kirby Rosplock
I mean, it is very complicated when you think about that level of ownership and offspring, as it relates to who's a family client?

03:23 - 03:33
Kirby Rosplock
Are there any exceptions, any unusual exceptions to the flat family client definition that might end up being allowed if they're not family?

03:34 - 03:40
Guin, David
Yeah, so, there's an ongoing question about the extent to which in-laws will be allowed.

03:41 - 03:46
Guin, David
So, there was a, there was some lobbying going on for a while to add in-laws.

03:46 - 03:57
Guin, David
So let's say that it's your family office, your husband is a family client because he's married to you, but your brother-in-law isn't in the same lineal change.

03:57 - 04:00
Guin, David
So you couldn't offer services to your brother-in-law.

04:01 - 04:17
Guin, David
There was some lobbing going on to try and get in-laws included that didn't come to fruition, but there are some no action letters out there asking for specific relief based on a specific set of facts and circumstances.

04:17 - 04:20
Guin, David
So there may be some movement in in that regard.

04:22 - 04:27
Guin, David
If the other part about the family AFS exemption is the ownership and control requirements.

04:29 - 04:35
Guin, David
And, when we say a family office has to be owned by family entities, that's the technical term under the rule.

04:36 - 04:39
Guin, David
It's important, remember, that can include key employees.

04:39 - 04:49
Guin, David
So, you can have a key employee that owns a piece of the family office or owns, you know, part of an investment vehicle that the family office advises.

04:50 - 04:53
Guin, David
But, those people cannot control the family office.

04:53 - 04:55
Guin, David
The family members need to control.

04:56 - 05:02
Guin, David
In the FAQs, it came out shortly after the rule really focused on the board of directors.

05:03 - 05:14
Guin, David
So, we were, we originally were always selling people, you know, at least a majority of the Board of Directors, or a similar governing body, like board of managers, if it's an LLC, need to be family members.

05:14 - 05:21
Guin, David
We've become a little bit more comfortable, in some cases, with moving those types of controls to the ownership level.

05:22 - 05:35
Guin, David
So, we might not have a Board of Directors that, yeah, it is, consist primarily of family members, but we may have taken a lot of the rights that would normally be exercised by the Board of Directors and move them back to the ownership level.


05:36 - 05:43
Guin, David
There are, you know, various planning techniques where you don't really want family members to be in control of an entity, like a board of directors.

05:43 - 05:44
Guin, David
So.

05:45 - 06:07
Kirby Rosplock
Well, and I think that's a really interesting area to delve a little bit more deeply into, I mean, you talked about recordkeeping as being a really important practice as part of compliance, and tell us more on how you see recordkeeping meringue to write demonstrating control, especially in this circumstance.

06:08 - 06:16
Guin, David
So, it's a great question because we know, hey, I like to approach these things as if the documents on drafting are an exhibit.

06:16 - 06:33
Guin, David
So, you know, when we create a been LLC agreement for a family office, for example, we, we draft into the document itself the requirements as to ownership and control so that it's a requirement for the entity to meet those standards.

06:33 - 06:38
Guin, David
Not just that it happens to be, that you meet them, but the document itself requires you to.

06:38 - 06:45
Guin, David
So we might say, for example, you know, you have to have, a board of directors must consist of a majority of family members.

06:45 - 06:52
Guin, David
Or, if they're an even number of family members and non family members, a family family member must have a casting vote.


06:53 - 06:56
Guin, David
So it's baked right into the terms of the agreement itself.

06:57 - 07:00
Guin, David
In that way, they're talking on the door, it's easy for you to show them.

07:00 - 07:03
Guin, David
Of course, I can apply my documents, require me to comply.

07:04 - 07:20
Kirby Rosplock
And you were telling me earlier about some new influences that our current state, and, particularly, virtual family offices, David can you talk to us a little bit about compliance policies, and what is new in the family office space.

07:21 - 07:25
Guin, David
So, you know, a lot of family offices may start with a general observation about compliance policies.

07:25 - 07:35
Guin, David
Lot of family offices, don't think they need compliance policies, because they're not subject to it regulatory compliance regime.

07:36 - 07:38
Guin, David
I think that's sort of missing the point.

07:38 - 07:44
Guin, David
I mean, the family needs to decide what's important to them, and then they need to draft compliance policies to deal with that.

07:45 - 07:50
Guin, David
So, for example, one of the things we spent a lot of time on, and many families are concerned about their privacy.

07:52 - 08:00
Guin, David
So, we will draft compliance policies about who must sign off on disclosures in a subscription agreement.

08:01 - 08:12
Guin, David
Because we don't know, we don't want someone who doesn't understand the family's desire not to disclose fact X, Y, or Z to the world at large filling out subscription documents without having somebody check them.

08:12 - 08:15
Guin, David
So, we want the compliance policies too.

08:16 - 08:19
Guin, David
It'd be tailored to what the family is concerned about.

08:20 - 08:24
Guin, David
You know, we have a lot of compliance policies as well, about who has the ability to move money.

08:26 - 08:31
Guin, David
No, it's, it's just, it's good common sense to have checks and balances in place.

08:31 - 08:44
Guin, David
You know, I'm sure everyone trusts their employees but you don't want to put anyone in a position that, you know and puts them in a place where they could, could benefit from some wrongdoing putting compliance policies in place.

08:44 - 08:45
Guin, David
That avoid that.

08:45 - 08:49
Guin, David
You know, as we've gone into the covert 19 World.



08:49 - 08:51
Guin, David
This was already happening to some extent but it's happening even more.

08:51 - 08:51
Guin, David
Now.

08:53 - 09:00
Guin, David
Haven’t compliance policies that deal with both the virtual world and multiple locations is.

09:00 - 09:00
Kirby Rosplock
Really.

09:00 - 09:01
Guin, David
Important.

09:01 - 09:04
Guin, David
So, figuring out how are you going to deal with those things.

09:05 - 09:15
Guin, David
And, you know, requiring, for example, that, you know, all documents must be stored in a, no accessible, electronic location.

09:16 - 09:21
Guin, David
The virtual world is always, we're making electronic recordkeeping much more important.

09:22 - 09:26
Kirby Rosplock
I think those are all really important areas.

09:26 - 09:36
Kirby Rosplock
I mean, do you want to talk a little bit more about why privacy is oftentimes an issue potentially for compliance and compliance and a family office?
09:36 - 09:41
Kirby Rosplock
And why families obviously want to not have as much information out there to the general public?

09:42 - 09:46
Guin, David
Yes, I think it's really to two main drivers of the privacy concerns.

09:46 - 09:54
Guin, David
One is a desire not to disclose too much information about the wealth holding structures.

09:55 - 10:03
Guin, David
So, you know, a lot of these beneficial ownership reports, for example, require you to go up the chain.

10:04 - 10:06
Guin, David
Getting to an alternate beneficial owner.

10:07 - 10:22
Guin, David
So, for families who have a concern about disclosing that level of information noted to whoever it may be that they're being or they have an off shore structure, and they don't want, you know, their home government, too, to understand exactly how their holdings structure works.

10:23 - 10:36
Guin, David
Or it could be a creditor issue, but we'll come up with specific structuring and reporting ideas that are designed to protect that type of information.

10:36 - 10:45
Guin, David
So, now we'll create a structure that allows us to stop at some point, going up the chain, before we get to the OTAs, the very top, but still comply with the rules.

10:45 - 10:54
Guin, David
So, there's that concern, and then, as you would suspect, there's also a concern about people just not wanting the general public to know what they own and how much they're worth.

10:55 - 11:11
Guin, David
So, we do a fair amount of work with an institutional investment manager, filing Richard Card 13 F, and there's the ability to claim a personal holding exemption.

11:12 - 11:24
Guin, David
So, if the filing would disclose the ownership of securities by a natural person, a trust or an estate, you can claim confidential treatment for actual securities.

11:25 - 11:29
Guin, David
And an interesting way in which the Family Office rule has affected other things.

11:30 - 11:51
Guin, David
We have been successful, for example, in getting the SEC staff to agree to expand the personal holding exemption by saying, well, if it, you know, if this file would identify the ownership by a group of identifiable people, natural persons, or trusts, then you should afford the same type of.

11:51 - 11:55
Guin, David
You know, confidential treatment to that information, as you would if it were a single individual.


11:55 - 12:07
Guin, David
So, we've, we've been filing on behalf of family offices, saying, you know, they are holdings as a whole because it's identifiable to a family, Should be afforded confidential treatment.

12:08 - 12:12
Guin, David
You, you get into some, some interesting questions about interpretation there, as well.

12:12 - 12:26
Guin, David
Because, a lot of times the question, whether foundation would, you know, knock you out of the ability to claim, because that's not among the types of entities that were listed in a in a personal holding exemption.

12:26 - 12:30
Guin, David
So, we have to deal with that sometimes and to deal with that question.

12:31 - 12:38
Kirby Rosplock
So, for the family office that doesn't have a Chief Compliance Officer, what advice?

12:38 - 12:47
Kirby Rosplock
What wisdom would you share about compliance in your office and in the merits of, you know, maybe working with an outside person in compliance?

12:47 - 12:53
Guin, David
Yeah, I mean, even if you don't have someone who's designated as a, as a chief compliance officer, and I would say, probably most family offices don't.

12:54 - 12:57
Guin, David
You should came in, At least no one who has that title.

12:58 - 13:03
Guin, David
You know, you should make it clear who in the organization holds responsibility for different things.

13:04 - 13:16
Guin, David
You Know, I do think it's probably in a family office best interest to work with an advisor, whether it be a lawyer or compliance consultant, to come up with a policy.

13:16 - 13:23
Guin, David
Um, you know, again, you need to build a bit careful because you don't want a policy that's overly burdensome.

13:24 - 13:32
Guin, David
You know, You wouldn't want to go, for example, and take a compliance policy for a fund manager off the shelf, and say, Well, this is, this is for me.

13:32 - 13:39
Guin, David
It's just going to contain a lot of stuff that isn't relevant family offices, And frankly, won't include some of the things that are relevant.

13:39 - 13:48
Guin, David
So, you know, it's not going to include the same type of concern about privacy, as you would want to have in a family office compliance policy.

13:50 - 13:53
Kirby Rosplock
This has been incredibly helpful, David.

13:53 - 13:58
Kirby Rosplock
Thank you so much for being here today as our featured guests on the Tamarind Learning Podcast, is your post Kirby Rossbach.

13:59 - 14:08
Kirby Rosplock
It's been another extremely helpful and relevant topic here, Family Office and compliance, we're really appreciative.

14:08 - 14:13
Kirby Rosplock
David was the author of Chapter seven of the Complete Family Office Handbook.

14:13 - 14:19
Kirby Rosplock
And we look forward to reading more about how to keep your family office compliant and the student age.

14:19 - 14:22
Kirby Rosplock
Thanks again David, pleasure that in there.

14:22 - 14:22
Kirby Rosplock
Thank.

14:22 - 14:23
Guin, David
You, Kirby.

14:25 - 14:27
Kirby Rosplock
This conference will now be recorded.

Withers – Bill Kambas and Ivan Sacks
14:29 - 14:31
Kirby Rosplock
Welcome to the Tamarind Learning Podcast.

14:31 - 14:33
Kirby Rosplock
I'm your host Kirby Rosplock.

14:33 - 14:40
Kirby Rosplock
And I'm pleased to have Ivan Sachs and Bill Kambas with me today from WithersWorldwide.

14:40 - 14:51
Kirby Rosplock
They are leading attorneys and co-authors, Chapter five of the Complete Family Office Handbook and focused on family office setup structure and operations.

14:51 - 14:53
Kirby Rosplock
We're thrilled to have you both here today.

14:53 - 14:54
Ivan Sachs
Thanks so much.

14:54 - 14:55
Bill Kambas
Thank you.

14:56 - 14:56
Kirby Rosplock
Good to be here.

14:57 - 15:05
Kirby Rosplock
So we're really excited to dig into the topic today of how do you pay for, structure and own a family office?

15:05 - 15:12
Bill Kambas
And, you know, paying for an office is one of those, you know, situations that you have to think long.

15:12 - 15:14
Bill Kambas
And think hard about, What are you creating?

15:14 - 15:15
Bill Kambas
How are you going to fund it?

15:16 - 15:19
Bill Kambas
Not just for today and tomorrow, but for decades to come.

15:19 - 15:33
Kirby Rosplock
And I'd love to dig in, just stepping into the pool of family office right now to talk about how do families typically set up and think about how to pay for the family office structure?

15:33 - 15:34
Kirby Rosplock
Bill?

15:35 - 15:36
Bill Kambas
Sure, thank you, Kirby.

15:37 - 15:55
Bill Kambas
And that's a very timely question as we have volatility in the market internationally and you know, families who is nothing new to the, are thinking about succession planning and the safeguarding and good stewardship of their assets.

15:55 - 16:03
Bill Kambas
So a family office is not an essential part, but it often plays a very important role in that family enterprise.

16:04 - 16:08
Kirby Rosplock
So the first way and you divide it up really nicely intentionally.


16:08 - 16:16
Kirby Rosplock
Or unintentionally, which is to divide up, setting it up and paying for it separately because I think you really have to take it in stride.


16:17 - 16:23
Kirby Rosplock
The question, the first question, is: Is this appropriate: what is the most appropriate arrangement for a family?


16:24 - 16:34
Kirby Rosplock
And, from there, we ended up, we can evaluate different opportunities for cash flow that would lead to the sustainability of the office within the overall enterprise.


16:35 - 16:47
Kirby Rosplock
Ideally, you do it in a way that is the least economically disruptive to the overall enterprise, and ideally, even furthermore, in a way that is a net benefit to the overall enterprise.


16:49 - 16:59
Kirby Rosplock
There are certain activities that need to be undertaken, and many of those activities require the participation of individuals who will get paid for that.


17:00 - 17:12
Kirby Rosplock
There are lots of different ways of dividing that up, and that's ultimately how we were back into, and work around, the payments, and funding aspect of running a family office.


17:12 - 17:14
Kirby Rosplock
So often, it wouldn't starting with that.


17:14 - 17:17
Kirby Rosplock
Is this the right thing for a family?


17:17 - 17:18
Kirby Rosplock
There's a driver.


17:18 - 17:27
Kirby Rosplock
There is somebody, or some constituent group of people in the family enterprise who will be encouraging the exploration of the family office.


17:28 - 17:32
Kirby Rosplock
Those are usually the folks who want to make the initial investment.


17:32 - 17:41
Kirby Rosplock
Many times it may be first as a senior generation, who is recognizing all the work that they have been doing, and say we need to professionalize this.


17:41 - 17:52
Kirby Rosplock
But it may also be a group of fiduciary trustees who say that they, themselves, as individuals, or a private trust company, is not best equipped to handle a certain set of tasks.


17:52 - 17:55
Kirby Rosplock
And they want a family office to actually be doing that.


17:56 - 18:06
Kirby Rosplock
It may be beneficiaries of trusts who want this service because of organizing just the various demands of being good stewards.


18:06 - 18:10
Kirby Rosplock
I mean, there's, there's quite a long list, which we won't go through right now.


18:11 - 18:24
Kirby Rosplock
But whichever group it is, or whichever individuals they are that want to have that discussion will often be the ones who invest in the time as well as the economic cost of setting up that family office.


18:24 - 18:29
Kirby Rosplock
And from there, we then move to what sort of strategies may allow it to be self sustaining.


18:30 - 18:39
Kirby Rosplock
So, I'm just really curious, is paying for and being the owner of the same thing, necessarily.


18:40 - 18:56
Kirby Rosplock
Now, it's often separated, actually, so that you have, in many cases, you will have a senior generation Or, you know, the promoters generation is, as Bill was describing there, will become the owners of the enterprise.


18:58 - 19:00
Kirby Rosplock
But that's certainly not necessarily how it's funded.


19:00 - 19:08
Kirby Rosplock
Family offices are structured like the business and sometimes they also want to really justified as a business.


19:09 - 19:16
Kirby Rosplock
And so how they build their customers for services as it were, whether that's, you know, entirely family members and trust.


19:16 - 19:19
Kirby Rosplock
Obviously we should set, we should set apart right now.


19:19 - 19:34
Kirby Rosplock
If they're becoming multi-family offices are taking in third party money and looking to actually, you know, turn a profit or cover the costs of the founding family by fees, you know, to other families.


19:34 - 19:41
Kirby Rosplock
That's, that gets you into, you know, it's a logic, but Speak ..., with single family offices, at the moment.


19:41 - 19:47
Kirby Rosplock
Often that promoting generation will be the elders, and they want governance control.


19:48 - 19:51
Kirby Rosplock
They want to know whether they're, they're inviting him to the control.


19:51 - 19:57
Kirby Rosplock
That entity as the next generation, is, which I think so.


19:57 - 20:06
Kirby Rosplock
So they'll want to own it, but they may have ideas about family equity and paying for it, what you would occur.


20:06 - 20:19
Kirby Rosplock
That leads to wanting children and Next gen, to understand that, if they're gonna take all of the admin assistants, time with their personal business interests, that stuff, then they should get a bill for that.


20:20 - 20:31
Kirby Rosplock
So, you know, oftentimes, it starts out with that first generation subsidizing costs, but over time, developing a model where you pay for the time of the employees that you use.


20:31 - 20:59
Kirby Rosplock
And, in many cases, what we see sophisticated family offices coming up with over time, especially when they get into further generations, is a mixed model on that, where you now have enough assets under management and multiple participants in obtaining services that you're charging and AUM type of fee.


20:59 - 21:06
Kirby Rosplock
To cover the costs of the office, which as potentially is important too, present day DACs, efficiencies.


21:06 - 21:17
Kirby Rosplock
And on the other hand, when it comes to, shall we say, walking the dog or, you know, the concierge services, that's where you want to make people pay for their play.


21:17 - 21:28
Kirby Rosplock
So that, you know, your staffing needs and stuff adds something to discipline, which is that, you know, people know to the extent they're going to take this time, they're going to have some some cost impact.


21:29 - 21:32
Kirby Rosplock
So, it'd be often becomes a mix.


21:33 - 21:45
Kirby Rosplock
And Bill, when you see the senior generation start to fade and maybe pass away, you see the next generation beneficial owners are in adulthood.


21:45 - 21:53
Kirby Rosplock
Now, talk to me a little bit about the transfer of what happens at an ownership level, and when we think about how we pay for this office structure.


21:54 - 21:56
Kirby Rosplock
I would imagine this is a critically tense period.


21:56 - 21:57
Kirby Rosplock
Right?


21:57 - 22:04
Kirby Rosplock
If you have family members who are beneficial owners who really didn't, I, I didn't intend to set this up by now.


22:04 - 22:10
Kirby Rosplock
I have to pay for this, Tell us what you've seen and what's the experience of families who do it well.


22:11 - 22:12
Kirby Rosplock
Certainly.


22:14 - 22:36
Kirby Rosplock
As family sophistication grows and his family member ship expands, I find a contrasting contraction of the ownership, rather, it's only those that are engaged, or even a structure that allows for voting rights, but not ownership of the family office.


22:36 - 22:36
Kirby Rosplock
Itself.


22:36 - 22:42
Kirby Rosplock
So, it really ends up becoming a consolidation of responsibilities.


22:43 - 22:58
Kirby Rosplock
And I also very much like the idea of in the end, we will explore non-stop corporate ownership, purpose, trust ownership, or now we have foundations in two states in particular, Wyoming and New Hampshire.


22:58 - 23:04
Kirby Rosplock
So, those offer some interesting, cutting-edge opportunities to have types of entities that may or may not have owners.


23:05 - 23:10
Kirby Rosplock
And I like that because what it does is it forces the funding required.


23:10 - 23:17
Kirby Rosplock
The funding requirement or responsibility to come from those using the services much like Ivan described.


23:18 - 23:45
Kirby Rosplock
I can alternative to that, or, another variation on it, because Ivan's, right, ultimately, it's complex, and it suits the needs of those who are using the services, but it almost becomes like, a club: one, my family members, that benefit from this, and trusts, and trustees that that require those services may have an annual nominal annual fee to ensure that there's a certain amount of running capital for basic uses.


23:45 - 23:46
Kirby Rosplock
And then after that, it goes on.


23:47 - 24:03
Kirby Rosplock
Similarly, when it comes up in property management contracts, where families acquire a fair amount of luxury properties, whether they're real estate in one jurisdiction or another, or boats and planes, things that have high running costs.


24:04 - 24:08
Kirby Rosplock
A lot of times, the family office is tasked with that, but not everybody's using it to the same degree.


24:09 - 24:16
Kirby Rosplock
What we do want to watch out for, though, is that the family office doesn't operate in such a consolidated manner.


24:16 - 24:32
Kirby Rosplock
So, as to simply be seen as managing one's own investments, In other words, the ownership of the family office tied closely to those who are using it and benefiting in the investment management context that comes with its real risks from a tax perspective.


24:32 - 24:40
Kirby Rosplock
We also need to be careful of the responsibilities when there are fiduciary duties that come up.


24:40 - 24:48
Kirby Rosplock
We have some IRS guidance and concerns over retained, control possession and enjoyment.


24:48 - 24:57
Kirby Rosplock
And so we want to be careful that those owning the family office and providing services don't encroach upon a fiduciary responsibility.


24:57 - 25:02
Kirby Rosplock
Then suggest that those who believe they had actually transferred assets did.


25:02 - 25:03
Kirby Rosplock
In fact, routine control.


25:03 - 25:07
Kirby Rosplock
So these are the different considerations that go into that, who owns the family office?


25:07 - 25:09
Kirby Rosplock
How does it succeeds in the next generation?


25:09 - 25:12
Kirby Rosplock
And then how does that complemented by funding?


25:13 - 25:13
Kirby Rosplock
Excellent.


25:14 - 25:25
Kirby Rosplock
Now, just in closing, Ivan, any last thoughts about best practices when paying for an office structure and or ownership considerations.


25:27 - 25:42
Kirby Rosplock
Well, I think, you know, whether the initial founders of a family office pay for it and choose for estate planning strategic reasons, or otherwise, you're happy to pay for it, or you go to a model where everybody's paying for it.


25:42 - 25:55
Kirby Rosplock
You know, as a big believer in the value that family offices add to families and to strengthen the past The retention of family wealth and growth across the generations.


25:55 - 26:09
Kirby Rosplock
I think it starts very much with education that the next generations are learning where that value add is, and not suddenly shocked to find costs going on here.


26:10 - 26:27
Kirby Rosplock
You know, Petulant, that is, you know, not unheard of dynamic, which you were alluding to, but you know, they have to see the value in the concentration of their purchasing power, they're, you know, the the group insurance.


26:27 - 26:33
Kirby Rosplock
That group benefits that they're getting the risk protection, they're getting, from having professionalized.


26:36 - 26:40
Kirby Rosplock
Management of the varieties of risks to wealth across generations.


26:40 - 26:46
Kirby Rosplock
And it's always hard, because it's not as easy to quantify you, know.


26:46 - 26:50
Kirby Rosplock
It's not easy to quantify what didn't happen to you when you got a divorce.


26:50 - 26:56
Kirby Rosplock
You know what didn't happen to you when someone asked away the family, and there was no taxes, Right.


26:56 - 27:14
Kirby Rosplock
So, so, I think the founding generation and the family professionals certainly an important, you know, element to educating family members as offices like that grow.


27:14 - 27:18
Kirby Rosplock
So that when they do see the cost, say, understand what they're getting for it.


27:19 - 27:22
Kirby Rosplock
Yeah, absolutely, Bill, any last closing thoughts?


27:22 - 27:29
Kirby Rosplock
Part of that value, Iven, was right to point out that there's a series of values that this can provide.


27:29 - 27:31
Kirby Rosplock
And I think that understanding that is so important.


27:32 - 27:35
Kirby Rosplock
It's a risk management tool in many families.


27:35 - 27:46
Kirby Rosplock
It's a, it's an entity that conserve in other roles, such as a manager, general, partner of underlying asset owning entities, which does ultimately help insulate individuals'.


27:46 - 27:52
Kirby Rosplock
It, also provides for income streams that are not otherwise available, and can be very advantageous to a family.


27:52 - 28:03
Kirby Rosplock
So, in addition to the group benefits, the economies of scale, that a family member gets there, is that risk management side of it, too, and continuity of family history.


28:03 - 28:11
Kirby Rosplock
So, all of this makes it a viable and important sort of option for the sophisticated or the organized family.

28:12 - 28:13
Kirby Rosplock
Excellent.

28:13 - 28:19
Kirby Rosplock
Thank you gentlemen so much for being here today, the Tamarind Learning Podcast, your host Kirby Rossbach.

28:19 - 28:20
Kirby Rosplock
I'm here with Ivan Sacks.

28:21 - 28:30
Kirby Rosplock
And with Bell Canvas, from whether it's worldwide, they are co-authors of Chapter five on Setup Instructure and Operating Family Office.

28:30 - 28:32
Kirby Rosplock
We're delighted to have you both here today.

28:32 - 28:34
Kirby Rosplock
Thank you so much for your time and sharing your wisdom.

28:35 - 28:36
Kirby Rosplock
Thank you.